ML20070H102
| ML20070H102 | |
| Person / Time | |
|---|---|
| Site: | 05000077 |
| Issue date: | 03/11/1991 |
| From: | Keene W CATHOLIC UNIV. OF AMERICA, WASHINGTON, DC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9103130256 | |
| Download: ML20070H102 (5) | |
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- 2 TIIE CATilOLIC UNIVERSrlT OF AMERICA Radiation Sqfety Office Iikshington, D.C. 200M 202 319-3206 Docket No. 50-77 11 March 1991 Licetu;e No. R-31 REPLY TO A NOTid 0F VIOLATION U.S. Nuclear Regulatory Commission Attn: Document control Desk Washington DC 20555 Gentlemen:
This letter is submitted in response to NRC REGION I letter dated 11 Feb 91 and
,igned by James H. Joyner, Chief, Facilities Radiological Safety and Safeguards Branch, Division of Radiation Safety and Safeguards, NRC Region 1. Appendix A to the lett 'r provides Notice of Violation with respect to certain Technical Speci-ficatione relating to the current " Possession Only" status of the license. Spe-ci;1c response to the Notice of Violation is made in Appendix A hereto.
Sincerely
/ g/,
Warren E. Keene, Ph.D.
Reactor Administrator and Director of Radiation Safety ENCL: Appendix A, Response to Notice of Violation cc w/ encl:
Regional Administrator, USNRC Region I Sr. Rosemary Donley, Executive Vice President Dr. William J. Keinhofer, Chairman, Mechanical Engineering Department Dr. John J. McCoy, Dean, School of Engineering and Architecture f
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App 0NDIX A RFSPONSE TO NOTICE Of VIOLATION The Catholic University of America Docket No. 50-77 Washington, District of Columbia License No. R-31 11 March 1991 This response relates to an announced inspection conducted on January 14-15 1991, during which violations of NRC requirenients were identified. The response is keyed to the Notice of Violation.
==
Introduction:==
Generic to several of the violations noted is the prior absence of published schedules for inspections, reports ari meetings requit ed to maintain compliance with the technical specificatians which remain in ef fect for the shut-down (and now def ueled) reactor. The Reactor Administ rator is preparing an appropriate schedule of inspections and reports for the guidance of the Chairman of the Radiation Safety Committee and eppropriate men.be r s of the university adminirtration. The Chairman of the Radiation Safety Conmat tee is publishing a schedule for quarterly meetings of the Conmiit tee for the balance of the university year (ending 31 August). Annual schedules for quarterly meetings 1
of the Committee will be published in September for subsequent years.
A.
Failure to hold quarterly meetings of the Radiation Safety Committee during 1988-1990 (A Severity 1evel V Violation).
1.
Reason for the violation:
Meetings were held 23 Mar, 27 Jun. & 15 Nov.
1988, 15 May & 25 Oct 1989, and 2 May, 25 Sep. & 18 Dec 1990. There being no business before the committee, the Chair refrained from calling pro forma meetings. Three of the four missed meetings would have been held during summer breaks; only in the first quarter of 1990 was a meeting missed during a regular semester. A requirement for at least one meeting per semester is considered more consistent with normal university opetations. No application for technical specification relief was made because of the pnssession-only status of the reactor and the fact that reactor fuel sately and security was not diminished by omission of the meetings.
2.
Corrective stets taken:
Meetings have been held in conformance with the technical specifications (2 May, 25 Sep. & 18 Dec 1990, and 15 Feb 1991) such that the licensee has been in continuous compliance since the second quarter of 1990. The citation pertains to prior pcriods.
3.
Corrective steps to be taken: Adherence to the published schedule, as amended from time to time.
4.
D_ ate of full compliance:
1 April 1990, i
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The Catholic University of Amer 2ca Docket No. 50-77 Response to Notice of Violation License No. R-31 Appendix A 11 Maich 1991 l\\.
Pailure to pe: form audits ( A Sevtrity Level IV Violation). (i. Annual audit by Radiation Safety Comittee of Technical Specification Con;pliance, and ii. 24-month audit of I'acility Emergency Plan and l'acility Security Plan. )
1.
Remn f or Viqtq1ttrp (1) railure of appointed auditor to conduct audit of technical specif 2 cation compliance and f ailure of heattor Admin 16-t rator to insist on audit ; (ia ) l ailure of Reac t or Administ rat or to submit revised emergency and security plans to the Committee for teview.
2.
Corrective steps taketp (i) The report of the 14 Mar 68 seactor inspection, together with a copy of the reactor technical specifications, was provided by the Reactor Administ rator to the Radiation Safety Commit tee prior to its meeting of 27 Jun 68. By memo of 1 Jul 88 the Chairman appointed a committee member to conduct the required audit. That indiv.tdual is no lonCer a member of the committee. (ii) The Eroergency Plan is Chapter
$ of the University Radiation Safety Manuait it is not reactor-specific.
It was reviewed and revised by the Director of Radiation Safety 2n August 1990. The Reactor Security Plan was thoroughly revised by the Reactor Administrator during 1990 and changes subn.it ted to NBC in Jan. Feb, Mar,
and Sep, 1990.
3.
Corrective Steps to be taken: (i) In accordance with the schedule ref erred to in the Introduction, above, the Beactor Administratot will submit an annual report of technical specification compliance to the Radiation Saf(ty Committee for audit. Interia quarterly reports of compliance will be submitted to the Committee. The Chairman of the Radiation Safety Committee will appolut a new auditor by 1 Apr 91 to conduct an audit for current compliance and to report findings to the Chairman within forty-five days.
(ii) The Emergency Plan, and the Reactor Security Plan, both as revlued in 1990, will be submitted to the Radiat ion saf ety Commit tee in time for review at its second quarter 91 meeting, it is anticipated that the reactor fuel will be returned to DOE before either plan will again be due for review.
4 Date of full compliance:
On or before 30 Jun 1991.
t Drinion:
During the period of the violation (1/88-12/90) the reactor fuel was either in the reactor or in exclusive-use safes (See Item C.I.)
The reactor was provided with enhanced fuel security measures which are a matter of NRC record; its fueled control and safety rods had been removed to a safe. rendering it a de f acto sub-critical assembly, and the control cable between the operator's console and the reactor had been reuoved and destroyed. rendering the reactor inoperable.
The security of the safes is claimed to be at least equivalent to that of the reactor structure. The reactor and the safes at e in the same room; it is provided with security features which are also a matter of NRC record.
The Catholic 11niversity of America Docket No. 50-77 i
Response to Notice of Violation License No. R-31 Appendix A 11 Harch 1991 B.5 (Cont.)
Consequently, the violation is of no more than rninor safety significance; it is clearly without environmental significance. Thes efore the violation should be reclassified as Severity Level V.
C.
Failure to make and record quarterly inventory and appearance check of the reactor fuel.
1.
. Discuss io r3:
The notice of violation indicates that there is no record of quarterly inspection and surveillance f rom 1/88-12/90. The reactor was defueled 17 Mar 90, in accordance with procedures submitted to the NRC. Prior to that, cornpliance was physically impossible because all fuel rernained encapsulated and the fueled core tank remained in the reactor. On 17 Mar 90, the cure tank was removed f rom the reacto, it was vented to an evacuated cylinder, and immediately moved (without defueling)
I to storage in a safet fueled safety and control rods had been removed pic-viously and placed in a separate safe. Safety Rod #1 w L defueled 11 Apr 90; the Control Rod was defue. led 16 May 90; and Safety Rod #2 was defueled 18 May 90. In each case the individual fuel segments were inspected, measured, weighed, the results recorded in the defueling/ decommissioning log, and the fuel segments returned to the safe the same day. (Particles collected from one rod segment which evinced slight deterioration of its cylindrical edges, were, in fact, shown to the inspector.) The core tank i
was defueled 25 May 90, at which time each piece of core-fuel was inspec-l ted, measured and weighed, the results recorded, and the fuel returned to i
the safe. On 5 Jul 90, nine of the larger core fuel segments were reweighed on a new balance, and the results logged. Prior to the indicated dates there was no opportunity te make an appearance check of the fuel. During the fourth quarter of 1990, the storage safe was accessed on more than oac occasion, in the company of the assistant to the Director of Radiation Safety. There was no evidence of any change in the appearance of the fuel.
Therefore, it appears that the only violation was failure to record the fourth quarter 1990 surveillance. This is an oversight.
2.
Corr.en. Live steps taken Incorporation of the quarterly inventory and surveillance into the schedule noted in the Introduction, above. Recording is to the defueling/ decommissioning loc.
3.
Steps to be taken:
spliance with the schedule of inspection and surveillance and periodic report of compliance to the Radiation Safety Committee.
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4 Date of full compliance:
15 January 1991 (Inspection and inventory in the company of the inspector).
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The Catholic liniversity of Arnerica Docket No. 50-77 Response to Notice of Violation License No. R-31 Appendix A 11 Masch 1991 D.
Failure to conduct a yearly test of the building fire alarm.
1.
Reason for the violation: The alarm was not tested during 1990. Fire alarm testing previously had been conducted annually by the university Safety Ot ficer. Due to a gap between terinination of that individual's employmeut and the creation and filling of the new position of Director of Environ-mental Safety. the Reactor Administrator overlooked informing the Director of F.nvi ronmen t al Safety of the technical specification r equi re:ae nt.
2.
Corrective steps taken:
The Director of Environmental Safety has been informed of the reactor technical specification requirement for annual fire alarm testing, and has scheduled a test for not later than 1 June 1990.
3.
. Corrective steps to be takn: The building fire elarm will be tested in connection with a building fire drill to be conducted as soon as mild weather is assured. A repos t of completion of the test will be made to the Radiation Safety Committee.
4.
Date of full compliance.
On or before 1 June 1990.
E.
Failure to make and record quarterly inspection of physical barriers (door and safe locks).
1.
Reason for violation:
There was no f ailure to make the inspection.
Ait pertinent locks are in regular use and their proper functioning is observed by the Reactor Administrator; the condition of door locks is noted by the Department of Public Safety in the course of regular Security Of ficer rounds. Failure to record is an oversight due to attention to other matters of radiation safety significance. It is noted that non-recording did not diminish the safety or security of the reactor fuel.
2.
Corrective steps taken:
The required surveillance for the current quarter has been logged in the r eactor defueling/ decommissioning log. The survei\\1 9nce requirement ir, incorporated into the schedule referred to in the Int.oduction. above.
3.
Corrective steps to be taken: Continued compliance with the schedule until the reactor fuel is removed from the campus and periodic report of com-pliance to the Radiation Safety Committee.
4.
Date of full complbttleg:
1 March 1991.
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